Albert C. Johnson - Page 5

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          Stennett is a British cattle breeder, doing business as The Cattle          
          Company.  He was one of the original importers of Belgian blue              
          cattle from Belgium to Britain.  Mr. Stennett is the past president         
          of the Belgian Blue Association.                                            
               Petitioner advertised his breeding operation (known as                 
          Johnson's Belgian Blue Cattle) in farmers' and/or cattlemen's trade         
               The offspring from petitioner's first heifer were outstanding;         
          petitioner won several awards in the United States. Others                  
          approached him with regard to finding Belgian blue cattle.                  
          Petitioner was unable to meet the demand for Belgian blue cattle            
          through his own operations.  Consequently, petitioner agreed to             
          broker the purchase and sale of Belgian blue cattle in the United           
          States for Mr. Stennett and others, notably a partnership                   
          consisting of the Vanderhayden family of Ontario, Canada, and               
          Orliin Pelton.3  In this regard, Mr. Stennett would send Belgian            
          blue cattle embryos--which had been "flushed" from Belgian blue             
          cattle in Britain, frozen, and then transferred--to Canadians4 such         
          as the Vanderhayden family, who would then implant the Belgian blue         
          embryos into non-Belgian blue heifers at the Vanderhayden farm.             

               3    The record does not contain any specific information              
          regarding Mr. Pelton.                                                       
               4    During the years in issue, U.S. law prohibited the                
          direct importation of Belgian blue cattle embryos from Britain to           
          the United States.                                                          

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